Greenmoss Builders, Inc. v. Dun & Bradstreet, Inc.

Dun & Bradstreet (defendant) mistakenly reported to a subscriber bank that Greenmoss Builders (plaintiff), a financially sound company, had filed for bankruptcy, an error traced to a 17-year-old employee's mistake reviewing bankruptcy filings; the bank terminated Greenmoss's credit as a result, and Greenmoss sued for defamation, winning $50,000 in actual damages and $300,000 in punitive damages from a jury. Dun & Bradstreet moved for judgment notwithstanding the verdict, which the trial court denied, though the court separately found it had given an incorrect jury instruction on the liability standard and ordered a new trial, certifying to the Vermont Supreme Court whether non-media defendants receive the same protections as media defendants in private defamation suits.